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basic meaning of international tax avoidance, international tax havens, transfer pricing
and related administration, common practices of international tax avoidance,
international anti-avoidance laws and regulations and so on. Jurisdiction Practice of
Anti-Avoidance walks participants through relevant jurisdictions’ practices and cases
of tax administration of transfer pricing, advance pricing arrangement, cost-sharing
agreement, controlled foreign enterprises, thin capitalization and general anti-
avoidance.

2.2.3 Cross-Border Income Tax Administration
Cross-border income tax administration mainly includes offshore tax administration
on resident taxpayers and domestic tax administration on non-resident taxpayers. In
recent years, with the deepening of global economic and trade exchanges, cross-
border income tax administration has become increasingly prominent.

This subtopic consists of three courses. Offshore Tax Administration walks
participants through different types of cross-border transactions, the types of
international tax jurisdiction, the concept and judgment criteria for tax residency, the
determination of the source of income, the relief of international double taxation
caused by the overlap of different tax jurisdictions, entitlement to treaty benefits and
so on. Introduction of Non-Resident Taxation shares the administration of non-
resident enterprise income tax, focusing on policies of non-resident enterprises with
permanent establishments and of withholding at source on the income of non-resident
enterprises. Jurisdiction Practice of Non-Resident Tax Administration summarizes
relevant management regulations and supporting administrative measures for cross-
border income tax administration of non-resident enterprises or non-resident
individuals in relevant jurisdictions.

2.2.4 BEPS Action Plan

The BEPS Action Plan is an international tax reform project endorsed by G20 leaders
and commissioned to the OECD, in which 15 action plan reports and an explanatory
statement are included. Each of the BEPS actions addresses weaknesses in existing
international tax rules or regulations, making recommendations on adjustments to
international rules and domestic law in order to enable countries (regions) to achieve a
coordinated and comprehensive response to BEPS.

The course BEPS Action Plan, as its name suggests, explains contents,
recommendations and achievements of the 15 BEPS Actions, such as digital economy,
hybrid mismatch and controlled foreign corporation rules.

2.2.5 Introduction of International Rules to Address the Tax Challenges Arising
from the Digitalization of the Economy

The digital economy has been booming in recent years, expanding in scale and
deepening in application. It has gradually become a key engine to promote economic
progress and high-quality economic development. However, the rapid development of
the digital economy in the global scope has brought many challenges to the traditional

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